In a decisive judgment with broad implications for legal academia and public recruitment, the Madras High Court has held that a one-year LLM degree, if approved by the University Grants Commission (UGC), is valid not only for admission into Ph.D. programs but also for public and university appointments. The court ruled in favor of Dr. Sangeetha Sriraam, who was denied appointment to the post of Assistant Professor (Human Rights) despite topping the written exam conducted by the Tamil Nadu Teachers Recruitment Board (TRB).
Background of the Case
The petitioner, Dr. Sangeetha Sriraam, applied for the post of Assistant Professor in Human Rights pursuant to TRB Notification No.2 of 2018. Belonging to the GT/GT(Women) category, she secured the highest marks in the written examination — 133 out of 175 — and was called for an interview. However, her name was excluded from the provisional selection list published on May 14, 2019, even though candidates with lower marks were selected.
Represented by advocate Mr. M. Nirmalkumar, Dr. Sriraam approached the High Court under W.P. No. 15473 of 2019, seeking to quash the selection list and direct her appointment.
Legal Issues and Arguments
The core legal issue revolved around the validity of her one-year LLM degree, obtained from the prestigious National Law School of India University, Bangalore. The State, represented by Mr. V. Umakanth, argued that the degree did not meet the eligibility criteria, which allegedly required a two-year LLM.
The TRB, represented by Additional Advocate General Mr. R. Neelakandan and Standing Counsel Mr. R. Siddharath, also supported this contention. The University Grants Commission (UGC), represented by Mr. P.R. Gopinathan, was later impleaded in the case.
Court’s Observations and Findings
Justice R.N. Manjula, presiding over the case, emphatically rejected the exclusion of one-year LLM candidates from public appointments, stating:
“When the one-year LLM programme is recognized by University Grants Commission (UGC) and that is accepted for the purpose of admission to Ph.D., I find no reason to reject it for the purpose of appointment.”
The Court observed that the TRB notification did not mandate a two-year LLM and only required 55% marks in a relevant subject from an Indian or accredited foreign university. Importantly, the judgment cited Suganya Jeba Sarojini v. Tamil Nadu Dr. Ambedkar Law University (2024 SCC OnLine Mad 367) and K. Parandhaman v. TNPSC (2024 SCC OnLine Mad 2210), emphasizing that degree duration should not arbitrarily disqualify otherwise eligible candidates.
“The qualification contemplated by the employer shall not make any arbitrary discrimination between equivalent and similar courses without any valid basis,” Justice Manjula noted.
She further remarked on the credibility of the petitioner’s institution:
“It is needless to state that the University in which the petitioner had done her one-year LLM course is one of the most reputed Law Schools in the country.”
Court’s Decision
The Court allowed the writ petition and quashed the TRB’s provisional selection list dated 14.05.2019. It directed the TRB to include Dr. Sangeetha Sriraam’s name in the selection list and ordered the State to issue her appointment order with retrospective seniority from the date on which lower-ranked candidates were appointed.
The Court also directed that:
- Notional seniority be granted from the earlier appointment date.
- Monetary benefits be given from the actual date of appointment.
- All attendant service benefits be extended.
The appointment order must be released within eight weeks of receiving the judgment copy.
